A Florida Supreme Court opinion clarified Florida criminal law as it concerns ineffective assistance of counsel in death penalty cases. The case of RANDOLF v. McNeil was ruled upon December 2009 by the Florida Supreme Court wherein the court rejected Randolph’s claims. In Florida the criminal laws concerning a criminal attorney’s level of competency standard holds that unless there is a reasonable probability that the result of the trial would have been different, the lack of investigation or other shortcomings of the criminal trial attorney would not justify a new trial. Florida follows a generally accepted analysis when a conviction is appealed and the basis of the demand for a new trial is ineffective assistance of counsel. Florida criminal defense attorneys who represent defendants in homicide cases in which the death penalty is sought must have a special license from the Florida Supreme Court that he/she is “Death Qualified”. In South Florida, specifically in Broward County there are 18 attorneys who have Board Certification in Criminal Trial Law. Attorney Ralph Behr is one of the Fort Lauderdale Criminal defense attorneys who are both Board Certified and Death Certified in death penalty cases.